Research report 2015 - Max Planck Institute for Tax Law and Public Finance

The phenomenon of double non-taxation: An analysis in light of the (ab)use of hybrid entities

Authors
Parada, Leopoldo
Departments
Abteilung für Unternehmens- und Steuerrecht
Summary
A project at the Max Planck Institute for Tax Law and Public Finance intends to clarify the phenomenon of double non-taxation and to advocate for its neutrality as an objective outcome. Using hybrid entities as an example of analysis, this work aims to demonstrate that the sole result of non-taxation should not be a matter of concern in any cross-border transaction. Instead, the real target should be in determining whether the natural disparities between tax legislations can be subject to abuse, and if so, how to counteract it.

For the full text, see the German version.

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